The new ministerial order on mandatory electronic invoicing

The electronic invoicing is mandatory in Spain is entering its final phase. This follows the publication as a Royal Decree of the new draft Ministerial Order , which marks the turning point that many companies have been waiting for. It specifies technical details, deadlines, and requirements that directly affect companies’ financial processes.

For CFOs and financial executives, this is a critical moment. In addition to complying with the mandatory requirement for electronic invoicing, they must adapt their systems, processes, and tax architecture, if they haven’t already done so. Let’s take a look at what this Ministerial Order entails, when it will become mandatory, and how to prepare.

From the Crea y Crece Act to the Ministerial Order on Mandatory Electronic Invoicing 

The requirement for electronic invoicing stems from the Crea y Crece Act, which aims to reduce late payments and digitize B2B commercial relationships. However, until now, the technical infrastructure needed to make this a reality was lacking.

Chronologically, the most important legal milestones have been:

• Create and Grow Act (2022), which introduced the requirement.
• Royal Decree (March 31, 2026), which establishes the general framework.
• Draft Ministerial Order (April 2026), which defines technical and operational requirements. 

This new draft is currently open for public comment (from April 17 to May 8), outlines basic aspects of electronic invoicing, such as:

• Invoice formats. 
• Cross-platform interoperability.
• Exchange systems.
• Traceability requirements.

The Ministerial Order is the final step in making electronic invoicing mandatory in 2026.

When will electronic invoicing become mandatory?

Under the current framework, the Ministerial Order will set the start date for the deadlines on October 1, 2026 (following its final approval). From that date onward, the transition periods will begin, depending on the size of the company.

Estimated timeline for implementing mandatory electronic invoicing

Type of business	Estimated timeframe from the effective date
Companies > €8 million in revenue	12 months
Empresas < 8M€ facturación	24 months

Therefore, these deadlines require that: 

• Large companies should be prepared by 2027. 
• The rest of the business community will be in 2028

For international companies, these deadlines are very demanding due to the complexity of their financial systems. 

Key Technical Provisions of the Ministerial Order

The approved draft introduces several technical requirements for electronic invoicing that directly affect invoicing and ERP systems.

1. Mandatory interoperability

One of the most important points is the requirement that all electronic invoicing platforms be interoperable. This means they must offer:

• Ability to send and receive invoices between different technology providers.
• Use of common standards.
• Elimination of closed ecosystems.

Example: A company using SAP in Germany must be able to exchange invoices with a supplier in Spain that uses a different platform without any problems.

2. Invoice Status Log

The following is introduced: a requirement to report the status of invoices: issued, received, accepted, rejected, or paid. This has a direct impact on three areas:

1. Cash flow management. 
2. Financial reporting. 
3. Tax compliance. 

Example: An issued invoice must have its status updated to “accepted” or “rejected” within a specific timeframe to ensure complete traceability.

3. Structured formats

The Order also defines specific formats to ensure automation. These include structured XML, Facturae (in certain cases), and other interoperable standards. Thus, it eliminates the use of PDFs and manual invoices that cannot be integrated. 

4. Public vs. private platform

The mandatory online invoicing model provides for two types of platforms: a a public government platform or certified private platforms. Businesses may choose, but if it is a certified private platform, it must offer interoperability, data synchronization, and reporting to the government. 

Implications for CFOs and finance departments

Mandatory electronic invoicing has strategic implications across the entire financial landscape. Specifically: 

• Automate the Procure-to-Pay (P2P) cycle. 
• Reduces manual errors. 
• It provides greater control over payments and collections.
• It provides real-time visibility into cash flow.

However, it also presents significant challenges, such as adapting legacy systems legacy systems, integration with multiple jurisdictions, and simultaneous compliance with international regulations.

What exactly does the requirement for electronic invoicing entail?

In practical terms, the regulations will require the following:

• Issuing invoices in structured electronic format.
• Mandatory acceptance of electronic invoices.
• Invoice exchange via interoperable platforms.
• Record of all invoice statuses.
• Digital archiving of invoices in accordance with tax regulations.

Therefore, every company—whether large or small, domestic or international—will need to adapt and adopt a solution that meets the following criteria: 

• Compatible electronic invoicing system.
• Integration with ERP.
• Real-time reporting capabilities.
• Integration with external platforms.
• Compliance with technical standards.

Example of the impact of this requirement on a multinational company

To keep things practical, let's look at an example. Imagine a multinational company that currently operates in Spain, France, and Germany. Currently:

• Invoices in multiple formats.
• In some countries, they still rely on manual processes.
• You have limited visibility into the status of invoices. 

Now that mandatory electronic invoicing has been approved by this Ministerial Order, you must use:

• Centralized system.
• Structured invoices in all countries. 
• Synchronized invoice statuses. 
• Automatic reporting. 

The expected result is a reduction in DSO (Days Sales Outstanding), a significant improvement in audits, and greater operational efficiency.

How can you start preparing now?

Waiting for the final approval of the Ministerial Order is a strategic mistake. Companies that act early will have a competitive advantage. 

So you don't get left behind, from easyap we recommend following these step-by-step instructions.

• Assess the current state of your billing system.
• Identify the gaps in relation to the new requirements. 
• Choose a solution that complies with international standards and is interoperable (easyap may be the best choice right now).
• Make sure your solution integrates with your ERP (SAP, Oracle, etc.).
• Automate your data flows. 
• Establish data quality policies. 
• Ensures the traceability of all billing. 

Be aware that failing to comply with the requirement for electronic invoicing can result in penalties, operational disruptions, audit issues, or a loss of competitiveness. Internationally, the risk is compounded by the coexistence of different regulations.

Frequently Asked Questions About the Ministerial Order on Electronic Invoicing

Does the mandatory electronic invoicing requirement apply to international transactions?

Yes, provided that the transaction is subject to Spanish B2B regulations. What’s more, many jurisdictions are adopting similar models.

Will it still be possible to use PDFs as invoices?

PDF may exist as a visual representation, but not as a valid primary format if it is not structured.

What if my provider isn't ready?

The regulations will require all stakeholders to adapt. Interoperability will facilitate the transition, but coordination will be necessary.

Is it mandatory to use the public platform?

No. You may choose certified private platforms, provided they meet the technical requirements established by law.

The publication of the draft Ministerial Order marks a turning point in the implementation of electronic invoicing in Spain. With deadlines already set and clear technical requirements in place, the question is: are you ready?

For CFOs, this is a strategic shift that impacts technology, processes, and compliance. Being proactive helps you avoid risks and boosts your efficiency and competitiveness. The comment period, open until May 8, offers a final opportunity to understand and adjust your strategy. After that, the final countdown will begin. At easyap, we’re here to help you take the next step, so contact us and we’ll analyze it together.